G.R. No. 31012 - People vs. Romualdez

Case Summary (G.R. No. 31012)

Applicable Law and Procedural Background

The case was decided in 1932, thus applying the 1935 Philippine Constitution (predecessor to the 1987 Constitution), and the Penal Code of the Philippines as amended by Act No. 2712. The crime charged was falsification of public and official documents under Article 300 of the Penal Code, with penalties prescribed accordingly. The Supreme Court initially deadlocked on the case; after a reorganization and rehearing, it delivered a decision affirming the conviction.

Facts of the Case

Estela Romualdez, appointed secretary to Justice Norberto Romualdez and one of the exam correctors, had custody of bar examination papers and was designated supervisor of correctors during the 1926 bar exam.
Luis Mabunay took the 1926 bar exam but initially obtained a general average of 72.8% with failing grades in Civil Law (63%) and Remedial Law (58%)—below the required passing average of 75%.
After the Supreme Court rejected an automatic passing grade for candidates with averages between 70% and 75%, the final official list nevertheless included Mabunay with a 75% average due to altered grades on the two subjects.
Investigation showed that the grades on Mabunay’s actual exam papers were erased and changed from 63% to 73% (Civil Law) and from 58% to 64% (Remedial Law). Estela Romualdez admitted that the altered grades were in her handwriting, but denied knowledge of Mabunay before trial.
Justice Norberto Romualdez testified that he authorized Estela to “revise” grades to “do justice” before knowing the candidates’ identities, but he had no knowledge or approval of the specific alterations later discovered.
Evidence showed that Estela had access to the list associating candidates’ names with exam papers at the time of alterations, implying knowledge of Mabunay’s identity. Also, Mabunay withdrew P600 from his bank account shortly before the results were published, and Estela deposited P400 around that time, suggesting possible collusion.

Legal Issues

Whether Estela Romualdez committed the crime of falsification of public and official documents by altering the grades on bar exam papers.
Whether Estela Romualdez had the authority to revise or change the grades as she claimed.
Whether Luis Mabunay participated in the crime as a conspirator or accomplice.
Whether the altered examination papers constitute “public and official documents” within the meaning of Article 300 of the Penal Code.
Issues regarding the admission and evaluation of evidence, including expert testimony on the merits of the grade changes.
Procedural issues concerning the defendants’ rights, including the right to speedy trial and due process.

Court’s Findings on Authority and Acts of Estela Romualdez

The Court accepted Justice Romualdez’s testimony that Estela was authorized to “revise” grades but only to correct perceived injustices and only before candidates’ names were known.
However, the Court found that Estela exercised this authority beyond the permissible limits, altering grades without consulting other supervisors or correctors and without recording or reporting such changes.
Estela altered only Mabunay’s compositions out of more than 1,000 candidates, and she failed to satisfactorily explain why these papers alone were revised or how the increased grades were justified.
The manner of alteration—erasing original grades and replacing them without her initials but leaving the correctors’ initials—indicated an intent to simulate authenticity and conceal her acts.
Evidence showed that the candidates' names had already been identified when she altered the grades, disproving her claim of ignorance of the papers’ ownership.
The Court found that these facts and unexplained irregularities showed willful and illegal falsification constituting a crime.

Court’s Findings Regarding Luis Mabunay

While there was no direct evidence connecting him to the actual alteration, circumstantial evidence including the timing of his bank withdrawal, Estela’s deposit, and his failure to explain this transaction suggested collusion.
Mabunay was found guilty as co-principal (not merely an accomplice) in the conspiracy to falsify the documents to secure his admission to the bar.
Mabunay’s failure to testify or produce evidence to explain suspicious facts weighed against him.

Legal Characterization of the Examination Papers and Alterations

The Court reaffirmed that examination papers for admission to the bar are public and official documents because the admission process is a judicial function.
The alterations – erasing and changing grades and attributing false statements to correctors – fall within the technical definitions of falsification under Article 300 of the Penal Code. Specifically, acts included:
- Attributing to persons statements they did not make,
- Making alterations changing the meaning of genuine documents, and
- Causing persons to appear to have participated in acts they did not perform.

Consideration of Authority to Revise and Extent Thereof

The Court doubted that Justice Romualdez conferred upon Estela the blanket authority to alter any grade at will without accountability.
Even assuming such authority was given, Estela exceeded it by revising grades after knowing the candidate's identity and without notifying or initialing the alterations.
Revocation or abuse of discretion does not negate criminal responsibility for falsification when unauthorized acts produce a false document.

Evidence and Expert Testimony

The Court excluded expert testimony on merit of grades offered by defense attorneys because proper proof would have been the testimony of the original examiners who prepared the questions and grading keys.
Defense's failure to produce such evidence was noted.
The Court declined to speculate on whether the grade increases were merited in substance, focusing instead on the illegality of the alteration process.

Procedural and Rights Issues

Estela’s admission of alterations was not immediate but came after extensive prosecution evidence and readiness to present handwriting experts.
The Court found no denial of due process or fair trial; the extensive record showed ample opportunity for defense.
Claims of denial of speedy trial were rejected; delays were attributable to case complexity and procedural acts including motions and rearguments.
The Court clarified penalties and accessory penalties under applicable laws, including perpetual disqualification from public office for Estela as a government employee and proper classification and increase of penalties for both accused.

Court’s Conclusion and Penalties

Estela Romualdez was found guilty beyond reasonable doubt as principal in the falsification of public and official documents. She was sentenced to eight years and one day prison mayor, fined 1,000 pesetas, and imposed perpetual disqualification from public office with accessory penalties.
Luis Mabunay was found gu

Case Syllabus (G.R. No. 31012)

Facts of the Case

Estela Romualdez, appointed secretary to Justice Norberto Romualdez of the Supreme Court and assigned as a corrector and supervisor during the 1926 bar examinations, was charged alongside Luis Mabunay, a candidate, with falsification of public and official documents.
They were accused of willfully and criminally extracting compositions of Luis Mabunay from the Supreme Court archives and illegally altering the originally given grades on these examination papers.
The grades in Remedial Law and Civil Law for Mabunay were alleged to have been erased from original scores of 58% and 63% respectively, and replaced with inflated grades of 64% and 73%, thereby raising Mabunay’s general average to the passing mark and enabling his admission to the bar.
The alteration was discovered during an investigation prompted by discrepancies between original grading records and later published results.
Estela Romualdez admitted authorship of the alterations but claimed authority from Justice Norberto Romualdez to revise grades before candidate names were known and denied prior acquaintance with Mabunay.
Mabunay did not testify, but evidence suggested potential connivance including unexplained financial transactions between the parties near the time of publication of the examination results.

Composition and Conduct of the 1926 Bar Examination

Justice Norberto Romualdez was designated chairman of the examination committee, appointed members of the committee for various subjects, and designated correctors responsible for grading.
Estela Romualdez acted as corrector for Political Law and supervisor over the correctors, a role informally recognized by Justice Norberto Romualdez.
The examination process included preparation of questions by the committee, followed by grading by designated correctors working independently, supported with memoranda and grading rules.
Candidate papers were identified by numbers, with candidate names sealed and only revealed after the grading and general averages were computed.
The corrected grades were tallied using an adding machine; two separate lists of results were prepared, one preliminary list with candidates identified by numbers only and a final list with names.

Admission of Authority by Estela Romualdez and Evidence of Alteration

Estela Romualdez admitted handwriting the altered grades on Mabunay’s compositions, acknowledging she performed the changes.
Justice Norberto Romualdez testified that he considered Estela Romualdez and Deputy Clerk Jeronimo Samson as supervisors with equal authority and stated he allowed Estela Romualdez to revise grades to do justice, provided revisions were made before names were known.
However, Estela did not report these changes to the chairman, nor did she follow the requirement of making changes only before candidate names were known.
The court found that alterations were made after the identities of candidates were revealed, demonstrating that Estela Romualdez knew Mabunay was the author of the compositions she altered.
Other circumstantial evidence, including the timing of financial transactions, suggested Mabunay’s participation and connivance in the falsification.

Contentions of the Prosecution

The prosecution argued that Justice Romualdez lacked authority to delegate to Estela Romualdez the power to revise or alter grades after grading by the correctors, especially in subjects she was not assigned.
Even if such authority was granted, it was to be exercised only in the interest of justice and before the candidates' identities were known; evidence indicated these conditions were not met.
Testimony indicated the alterations were made to deliberately benefit Mabunay by raising his grades to the passing average, thus prejudicing the public.
Mabunay’s withdrawal of funds shortly before publication, and Estela’s subsequent bank deposit, was presented as circumstantial evidence of conspiracy.

Contentions and Defense Theory of the Accused

The defendants contended that Estela Romualdez acted within the authority granted by Justice Norberto Romualdez, who had wide discretion as chairman in the 1926 bar examination.
They maintained that Estela did not know the identity of Mabunay when correcting the papers, as the names were only revealed near publication.
Defense denied any improper relation between Estela and Mabunay, and emphasized alleged procedural irregularities by the prosecution.
They sought admission of expert testimony to prove the altered grades were merited, which was rejected by the court.
Argued that any improper conduct wou